https://xnet.maadix.org/nextcloud/index.php/s/NZX7cxbQSETid6g
Looking at this, I have a few points (though, I'm not entirely sure how it'd work out in practice):
1) The conditions for "reasonable suspicion" seem a bit vague. It feels the language could be stretched.
2) Presumably, the proportionality requirements might limit this (or to some extent), but one requirement for being served a detection order is that a service has been known to have been used to disseminate this content (no reference to frequency or volume) within the past year. That seems... Very broad?
3) Taking action to "prevent" things is fairly vague / broad, and could be a threat to freedom of expression, due process, or privacy.
Though, it seems like more of a strong suggestion in this particular document than mandatory per se?
4) Some terms look okay at first glance, but only when you completely ignore that lobbyists (including the religiously motivated group, International Justice Mission) are pushing for them to be interpreted in harmful ways (i.e. "child" not being an actual child).
International Justice Mission is not a new name. They've been accused of progressive groups previously of exaggerating rates of sex trafficking and of being anti sex work.
In a submission over chat control, they submitted a rather sleazy and manipulative proposal where they pointed to "terminology guidelines". These guidelines are far less guidelines than they are puritanical propaganda of how they want terms to be interpreted.
Usually, this is in a very harmful manner. A victim / survivor writing about their abuse? Well, you have just produced "child porn" and we've got to investigate you. IJM doesn't really care about the harms of what they do though. These kinds of groups never do.
https://qoto.org/@olives/111306160700543981 I think this is talking about the same thing, although the things people are mentioning there doesn't seem to jive with this particular text. Perhaps, I'm missing something.